Having an opinion of where corporate compliance and ethics should report outside of legal is like the opening sequence to Indiana Jones: Raiders of the Lost Ark.
Indiana carefully makes his way through the jungle, while his colleagues are taken out by traps. But Indy is cautious and experienced. He gets deep into the jungle following his map to find the caverns with the ancient artifact. He navigates the traps of the cavern to get the treasure, he works meticulously. He finds the gold idol, and then chaos breaks loose.
The cavern begins collapsing, he is betrayed, traps are sprung as he runs, the huge boulder comes crashing down behind him, the local natives chase him to his plane. He barely escapes with his life.
Having an opinion that compliance and ethics should report outside of legal tends to upset some of the natives of legal. Despite caution, careful crafting of argument, and presentation you find that some natives of legal are upset as you just rocked their domain.
You may have guessed, but I am an advocate that corporate compliance and ethics need to report outside of legal and have direct lines of communication to senior executives and the board.
[THE REST OF THIS ARTICLE CAN BE FOUND ON THE MITRATECH BLOG WHERE GRC 20/20’S MICHAEL RASMUSSEN IS A GUEST AUTHOR]